BEST WESTERN
INTERNATIONAL, INC. PRIVACY POLICY
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| Best Western International, Inc. and its subsidiaries
(collectively,
"BWI") are committed to taking measures to respect and protect
your privacy. This privacy policy sets forth the measures we take with
regard to how we use, protect and allow others to view your personal information. |
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| In particular, BWI is committed to complying with
all applicable data privacy regulations, including the European Community
Directive on Data Protection, commonly referred to as the "EU Privacy
Directive" and Canada's Personal Information Protection and Electronic
Documents Act ("PIPEDA"), as well as other applicable data privacy
regulations. |
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| BWI has chosen to comply with a number of international
regulations by joining the US Department of Commerce's "Safe Harbor" program.
BWI's implementation of the Safe Harbor requirements satisfies its obligations
under PIPEDA and the EU Privacy directive. In order to join the Safe Harbor
Program, we have submitted certain certifications to the US Department
of Commerce and details of such certifications may be found at the following
website: |
| http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list. |
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| Our privacy policy addresses certain principles
dictated by the Safe Harbor Program and consistent with the EU Privacy
Directive and PIPEDA: Notice, Choice, Onward Transfer, Security, Data Integrity,
Access and Enforcement. Further information about how we address these
privacy principles is provided below. |
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| 1. Notice |
| The purpose of this section is to notify you about
the manner and the purposes for which BWI may collect and transfer certain
personal information. This privacy policy should be read in its entirety
because anyone who submits personal information to BWI has certain rights
regarding the use, collection and transfer of such personal information. |
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| BWI maintains centralized reservations systems,
a worldwide accessible website, call centers and database computers in
the United States as well as in other locations around the world which
are intended to help BWI conduct business and to facilitate the operation
and maintenance of a central reservations system and its frequency marketing
program known as "Gold Crown Club International" ("GCCI").
The central reservations system and GCCI are maintained for the benefit
of its member hotels and properties ("BWI Properties") as well
as for BWI "Affiliates" which are entities which operate groups
of various BWI Properties outside of the United States. BWI Properties
and Affiliates are independent entities not owned or controlled by BWI
and may or may not be located in European Union member countries, Canada
or countries whose privacy protection laws have been deemed "adequate" pursuant
to the EU Privacy Directive, PIPEDA or other applicable regulations. |
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| BWI may collect certain personal information from
and about individuals which can be identified with such specific individual,
including without limitation, contact and payment information ("Personal
Information") about customers who (i) wish to stay or make reservations
at BWI member properties; (ii) purchase Travel Cards (stored value cards
redeemable for stays at BWI member properties) which may be used or transferred
to third-party recipients for stays at BWI member properties; or (iii)
are the users of Travel Cards. Direct customers, Travel Card purchasers
and users shall hereinafter collectively be referred to as "Travelers".
Personal Information about Travelers may be collected through our websites,
by our call centers or may be passed on to us by BWI Properties, Affiliates
or other third parties. Personal Information about Travelers is collected
so that Travelers can make reservations at BWI Properties and so that BWI
Properties can receive and have updated reservation information about Travelers
who wish to stay at such BWI Properties. Some of a Traveler's Personal
Information (such as a credit card number) may be stored to facilitate
the making of future reservations by such Traveler. Only that Personal
Information which is reasonably required to facilitate travel reservations
is collected and shared between BWI, BWI Properties and Affiliates as outlined
above. Personal Information for Travelers will be transferred from BWI
to BWI Properties and Affiliates. |
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| BWI may collect Personal Information from Travelers
who are also members of the GCCI program ("GCCI Customers") so
that BWI can perform certain administrative tasks necessary for the administration
and operation of the GCCI program such as the following: (1) allow GCCI
Customers to earn rewards, points or credit ("GCCI Points") for
staying at various BWI Properties; (2) allow other BWI Properties and Affiliates
to be aware of the GCCI Points earned by GCCI Customers so that such BWI
Properties or Affiliates can redeem GCCI Points; (3) allow BWI Properties
and Affiliates to receive and share Personal Information for GCCI Customers
as necessary in order for such BWI Properties and/or Affiliates to satisfy
contractual obligations among and between various BWI Properties and/or
Affiliates. GCCI Customers' Personal Information may be collected through
our various websites, by our call centers or may be passed on to us by
BWI Properties, Affiliates or other third parties. BWI may transfer Personal
Information to BWI Properties and Affiliates as a part of BWI administering
the GCCI program as outlined above. |
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| BWI distributes Personal Information about GCCI
Customers to third parties for the purpose of having such third parties
compile information about the type and frequency of use of the GCCI program
by such GCCI Customers as well as to allow such third parties to conduct
data processing for BWI and to engage in communications on behalf of BWI
with GCCI Customers. BWI may also distribute Personal Information to airline
companies upon request of the GCCI Customer, in order to allow a GCCI Customer
to earn frequent customer points with such airline companies. Examples
of these types of third parties include Direct Options and Cendyn. |
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| BWI may send marketing information about BWI, BWI
Properties or the GCCI program as well as marketing information about offers
or information about third party products and services to GCCI Customers
and Travelers based upon the Personal Information BWI has collected for
such GCCI Customers and Travelers. |
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| BWI performs certain of its administrative tasks
through the use of several wholly owned subsidiaries ("BWI Subsidiaries")
which generally operate within the same facilities as BWI, employ personnel
who are also BWI employees and use the same equipment to store and process
Personal Information as BWI. This privacy policy applies to and is adhered
to by the BWI Subsidiaries. BWI may share or transfer Personal Information
with BWI Subsidiaries while performing the tasks described in this privacy
policy. |
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| To serve you better, we may combine information
you give us online, at BWI Properties, through the mail, or in any other
way. We may also combine that information with publicly available information
and information we receive from others or cross-reference. We use that
combined information for the purposes described in this privacy policy. |
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| Although unlikely, in certain instances we may disclose
your personally identifiable information when we have reason to believe
that it is necessary to identify, contact or bring legal action against
persons or entities who may be causing injury to you, to BWI or to others.
We may also disclose your personally identifiable information when we believe
the law requires it. |
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| BWI takes special care to protect the safety and
privacy of children. Our web sites are general audience sites. We do not
permit anyone under the age of 13 to register with us, enter the GCCI program
or make hotel reservations. We also do not send email correspondence to
anyone who tells us that they are under the age of 13. |
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| Children under the age of 13 should always ask their
parents or guardians for permission before providing any personal information
to anyone online. We urge parents and guardians to participate in their
children's online activities and use parental control or other web filtering
technology to supervise children's access to the web. |
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| Our web sites and emails may use "cookies" and
other computer code processes, such as "web beacons". These are
small amounts of computer code that interact with your computer, browser
or email. Generally, we use cookies to remind us of who you are, tailor
our services to suit your personal interests, to process your reservations
or requests, track your status in our promotions, contests and sweepstakes,
and/or to analyze your visiting patterns. You can generally set your browser
to not accept cookies or to notify you when you are sent a cookie, giving
you the chance to decide whether or not to accept it. |
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| We may contract with third parties who may use cookies
or web beacons on our websites and collect information on our behalf. These
third parties are prohibited by our contracts with them from sharing that
information with anyone other than us or other third parties providing
services to us. |
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| 2. Choice |
| All Travelers, GCCI Customers and anyone else who
submits Personal Information to BWI may choose to not have any of their
Personal Information submitted or transferred to third parties in accordance
with the terms of this privacy policy. Please see below for further details. |
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| If you do not wish for your Personal Information
to be disclosed to any third parties, besides BWI Affiliates, and BWI Properties,
please let us know through our Customer Relations Department. The contact
information for the BWI Customer Relations Department is located at the
end of this privacy policy. Within a reasonable time after receiving your
request to not distribute your Personal Information to such third parties,
we will cease any distribution to such third parties. Please be aware that
if you choose to not have your Personal Information distributed to such
third parties, then we may not be able to provide all of the available
GCCI services to you or such services may not be delivered as quickly. |
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| If you do not wish for your Personal Information
to be disclosed to BWI Affiliates or BWI Properties, please let us know
through our Customer Relations Department. The contact information for
the BWI Customer Relations Department is located at the end of this privacy
policy. Within a reasonable time after receiving your request to not distribute
your Personal Information to BWI Affiliates or BWI Properties, we will
cease any distribution of your Personal Information to any BWI Affiliates
or BWI Properties. Please keep in mind that if BWI cannot disclose or share
your Personal Information to our BWI Affiliates or BWI Properties, we may
be unable to provide you with all or certain reservation services, other
services or GCCI related benefits. |
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| 3. Sensitive Information |
| BWI will only collect sensitive Personal Information
related to your health if you submit such type of Personal Information
and such sensitive Personal Information will only be used by BWI in order
to allow us to help you obtain special accommodations or other health related
benefits at a BWI Property. This type of Personal Information will be submitted
to BWI Properties and Affiliates only if necessary for us to facilitate
the reservation of a room at one of the BWI Properties which will help
meet your health needs. If you do not want us to collect and use such type
of Personal Information, please do not submit such type of Personal Information
to us. |
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| 4. Onward Transfer |
| Please note that our descriptions of our activities
under the "Notice" and
"Choice" principles above describe certain transfers of Personal
Information that BWI will be making to third parties. |
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| BWI wants all individuals who submit Personal Information
to BWI to understand that anyone who submits Personal Information, by submitting
such Personal Information and checking the appropriate box which indicates
that such individual is consenting to the use and transfer of Personal
Information in accordance with this privacy policy, authorizes certain
data transfers of such Personal Information to BWI Properties, BWI Subsidiaries
and/or other third parties ("Transfer Recipients") for use of
such Personal Information by Transfer Recipients in accordance with the
description provided in the "Notice" section. Transfer Recipients
may not necessarily be in the European Union, Canada or countries which
have been deemed by the European Union and/or Canada to have "adequate" data
protection laws, and may be in territories like the United States where
an equivalent level of data protection is not granted. |
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| 5. Security |
| BWI has conducted an internal review of its data
collection and processing practices and the security measures it has implemented
and believes that such security measures provide reasonable precautions
against the unauthorized access, disclosure, alteration or destruction
of Personal Information that BWI collects. |
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| BWI's Systems Architecture group has also conducted
an internal review of its computer network and its data protection measures
and believes that it has implemented a reasonable level of technology and
software to protect against the loss of Personal Information. Such measures
include without limitation, the following: the use of several firewalls
to separate user network traffic from server network traffic; the use by
BWI web applications of SSL encryption whenever sensitive information is
being accessed; the use of the Secure File Transfer Protocol (SFTP) when
exchanging data with third parties so that files, usernames and passwords
are encrypted; the use of intrusion detection software at eleven different
points in the internal BWI network and the use of virus protection software
on BWI's e-mail servers and client computers. |
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| BWI has also implemented certain physical security
measures to protect against the unauthorized access to Personal Information.
All server rooms are protected through a keycard system that checks user
privileges against a central database and these server rooms are locked
at all times. |
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| 6. Data Integrity |
| BWI has conducted an internal review of its data
collection and processing practices and believes that only that Personal
Information is collected and processed which is required in order for BWI
to provide services for or to fulfill its contractual obligations with
Travelers, GCCI Customers, BWI Properties and BWI Affiliates. BWI will
be implementing a periodic review of its data collection and processing
practices to ensure that it only collects or processes Personal Information
which is required in order for BWI to provide services for or to fulfill
its contractual obligations with Travelers, GCCI Customers, BWI Properties
and BWI Affiliates. |
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| 7. Access |
| BWI will make a good faith attempt to allow all
Travelers, GCCI Customers or others who BWI collects Personal Information
from, to have the opportunity to view the Personal Information it has collected
for such individuals, to the extent required by applicable regulations.
BWI may make certain Personal Information available through an on-line
program, website or procedure ("On-Line Procedure") for inspection
by the individual associated with such Personal Information. If Personal
Information is available through the On-Line Procedure devised by BWI,
the Personal Information can only be reviewed through such On-Line Procedure.
The On-Line Procedure will also contain information about how to request
any corrections or deletions of any erroneous Personal Information. Information
about the availability of On-Line Procedures for viewing certain types
of Personal Information is generally available at the website or on the
printed materials where such type of Personal Information was first submitted. |
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| If BWI has not set up an On-Line Procedure to allow
the viewing of Personal Information, then those Travelers, GCCI Customers
or others who submitted Personal Information to BWI for use by BWI can
review the Personal Information collected for them by contacting the BWI
Customer Relations department through the contact information provided
below. BWI will make all corrections and/or deletions of erroneous Personal
Information brought to its attention within a reasonable time period and
as required by applicable data privacy regulations. To the extent permissible
and in compliance with applicable data privacy regulations, BWI shall make
all corrections and/or deletions of erroneous Personal Information in a
manner which does not impose undue burden or expense on BWI. |
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| 8. Enforcement |
| BWI engages in self-assessment on a periodic basis
in order to determine its continued compliance with the requirements of
the Safe Harbor program, PIPEDA and the terms of this privacy policy. When
engaging in a self-assessment review, BWI engages an outside law firm to
help coordinate its review of its then current data collection practices
and at a minimum, at least one representative from BWI's finance, information
services, technology services and marketing groups or divisions is involved
in the self-assessment. |
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| 9. Dispute Resolution |
| All Travelers, GCCI Customers or others who submit
Personal Information to BWI and who feel that BWI has mishandled their
Personal Information in violation of the Safe Harbor requirements and/or
PIPEDA ("Disputing Party") should contact BWI through its Customer
Relations department (with such contact information provided below) with
a written description of their complaint. After receiving such written
description, a representative from BWI's Customer Relations department
will contact the Disputing Party to set up a time and manner to discuss
the Disputing Party's complaint. BWI is interested in addressing all legitimate
complaints about its adherence to the Safe Harbor and/or PIPEDA, and believes
that a Disputing Party and BWI should make a good faith effort to engage
in communications to work out or settle any of a Disputing Party's complaints.
If these good faith efforts fail to resolve the dispute, then the Disputing
Party shall have the opportunity to make use of an independent, dispute
resolution procedure. Currently, BWI is a member of the BBBOnline Dispute
Resolution Program and has agreed to allow Disputing Parties to bring privacy
complaints against BWI pursuant to the rules and procedures of such program.
Any Disputing Parties who wish to lodge a complaint through the BBBOnline
Dispute Resolution Program will be provided with information from BWI about
how to proceed with lodging a complaint. |
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| If BWI agrees to adopt the services of another independent,
dispute resolution procedure, it will do so only after revising its privacy
policy to reflect such new procedure and by informing all Disputing Party's
of such change. |
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| A Disputing Party and BWI may agree to use an independent
dispute resolution body or procedure to resolve disputes about BWI's compliance
with the Safe Harbor and/or PIPEDA upon mutual written agreement of both
parties. |
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| 10. Remedies |
| If it is determined by an independent dispute resolution
body or procedure that BWI has engaged in behavior not in compliance with
the requirements of the Safe Harbor and/or PIPEDA, BWI may be ordered to
engage in actions necessary to reverse or correct any actions taken by
BWI which were in violation of the Safe Harbor and/or PIPEDA and which
were harmful to the Disputing Party. BWI may also be required to take all
actions deemed necessary for BWI to be in compliance with the Safe Harbor
and/or PIPEDA in the future. BWI's non-compliance with the Safe Harbor
and/or PIPEDA may be reported to the appropriate governmental authorities
if BWI has engaged in a pattern of persistent failure to comply with the
Safe Harbor and/or PIPEDA. |
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| 11. Links to Third Party Sites |
| Our web sites may contain links to web sites operated
and maintained by third parties, over which we have no control. Privacy
policies on such linked sites may be different from our privacy policy.
You access such linked sites at your own risk. You should always read the
privacy policy of a linked site before disclosing any personal information
on such site. |
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| BWI reserves the right to modify this privacy policy
at any time without prior notice. The privacy policy posted on this Web
site will be the current version dated with the last revision date. Any
changes will apply to all information collected by BWI, including previously
collected information. Users are responsible to regularly review these
terms and conditions. User's continued use following any such changes shall
constitute acceptance of such changes. |
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| Last updated: September 9, 2004 |
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| CONTACTING BEST WESTERN INTERNATIONAL,
INC. IF YOU HAVE QUESTIONS OR COMMENTS If you have any questions or comments about
the manner in which we use or share your Personal Information, please contact
our customer relations department through the contact information included
below. Our customer relations department will coordinate with our designated
Privacy Officer or others to best address any comments, questions or requests
that you may have: |
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| Best Western International, Inc. |
| Customer Relations Department |
| Telephone: 1-800-528-1238 |
| Fax: 623-780-6199 |
| Email: customerservice@bestwestern.com |
| Regular Mail: PO Box 10203 |
| Phoenix, AZ 85064 |
| Attn: Customer Service |
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